Is CaliberMind GDPR compliant?

What does CaliberMind do?

Revenue attribution that merges web sessions with CRM records to credit each marketing touch. Because the merge reidentifies a session that began anonymously, treat it as consent-based rather than necessary.

Does CaliberMind need consent?

Yes. CaliberMind is Analytics, which is never strictly necessary for a website to function. Under ePrivacy Article 5(3), and its national transpositions, storing or reading anything on the device for that purpose requires consent first, and that consent has to be as easy to refuse as it is to give.

ePrivacy Art. 5(3) · TDDDG § 25 (DE) · TKG 2021 § 165(3) (AT) · GDPR Art. 6(1)(a)

Does CaliberMind send data outside the EEA?

Yes. CaliberMind processes data outside the European Economic Area, so you need a transfer mechanism under Chapter V and you have to say so in your privacy policy. In practice this means standard contractual clauses, or a provider certified under the EU-US Data Privacy Framework.

GDPR Art. 44 · GDPR Art. 46

How do we detect CaliberMind?

We load your page in a real browser as a first-time visitor who clicks nothing, then look at what it contacted. CaliberMind is recognised by requests to calibermind.com, and we report whether it merely loaded or actually sent data, and whether it set a cookie before any choice was made.